Staples v. U.S.
SCOTUS - 1994
- Police executed a search warrant on D's home and found a modified AR-15 (variation of M-16).
- The gun had been modified to make it an automatic weapon (filed down a stop).
- D was indicted for unlawful possession of an unregistered machine gun in violation of 5861 of the National Firearms Act.
- D asked for a jury instruction that required gov't to prove beyond a reasonable doubt that D knew that the gun would fire automatically. Court refused.
- Trial court found D guilty.
- 4th Cir COA affirmed, D guilty.
- SCOTUS reversed, remanded.
- Should a court consider the severity of the penalty when determining whether Congress intended to eliminate a mens rea requirement?
- A court should consider the severity of the penalty when determining whether Congress intended to eliminate a mens rea requirement.
- In a usual case, the government must show that the D knew the facts that made his conduct illegal.
- Offenses that require no mens rea are general disfavored. Congressional intent must be consulted to see if the omission was intentional.
- Generally, offenses punishable by imprisonment cannot be public welfare offenses and require mens rea.
- Congress clearly did not intend to make ignorant gun owners criminals.
- Stevens - The NFA is a public welfare statute.
- Owning the unmodified version of the gun is certainly not completely innocent.
- Must prove that D had K as to the characteristics of the gun.
- Courts can sometimes import MR into statutes if they believe that was Congress's intent.
- Severe punishment involved?
- Something that can cause problems legally?